Patient & Genetic Data Notice.

Your data are processed by İMSA Sağlık Hizmetleri Sanayi ve Ticaret (Halkalı V.D. 474 060 3681), as data controller, under applicable Turkish data protection law and, to the extent applicable, the GDPR. For any question or to exercise your rights, contact [email protected].

This Notice applies when you submit a molecular (NGS) report and related clinical information for a second-opinion review. It covers the clinical, genetic and AI-evaluation data described below. It does not replace the consent forms and information you receive from your treating physician or testing laboratory.

• Identity and contact data: name and contact details of the person submitting the case and, where provided, the referring physician.
• Clinical data (special category): diagnosis, tumor type and stage, prior treatments and other medical information needed to interpret the report.
• Molecular / genetic data (special category): the NGS / molecular report itself, variants, biomarkers and related sequencing results.
• Evaluation data: the structured analysis and the second-opinion report produced for your case.

We process these data to prepare and deliver the molecular second-opinion advisory you request, to communicate with you and any physician you nominate, and to keep records required by law.

• Special-category (health/genetic) data: processed only on the basis of your explicit consent (applicable Turkish data protection law; GDPR Art. 9(2)(a)).
• Performance of the service: the conclusion and performance of our advisory engagement (GDPR Art. 6(1)(b)).
• Legal obligations: record-keeping and other duties required by law (GDPR Art. 6(1)(c)).

Our analysis is AI-assisted and physician-led. Large language models running on AWS Bedrock (EU / Frankfurt region) help structure and analyse the case, and every report is reviewed, corrected and signed by the physician before delivery. The AI is a support tool; it does not make the clinical decision.

We share your data only as needed to deliver the advisory: with the physician who reviews your case, with any physician you nominate, and with carefully selected sub-processors (such as secure cloud infrastructure and the AI platform described above) that process data only on our instructions and under confidentiality obligations. We do not sell your data and do not share it for marketing.

Our AI processing runs in the EU (Frankfurt) region. Where any processing involves a transfer abroad, it is carried out with appropriate safeguards under applicable Turkish data protection law and GDPR Chapter V, and special-category data are transferred only within the scope of your explicit consent.

We retain your clinical, genetic and evaluation data only for as long as necessary for the purposes above and for the periods required by applicable law, after which they are deleted, destroyed or anonymised. If you withdraw your consent, we stop processing and delete the data unless we are legally required to retain specific records.

We apply appropriate technical and organisational measures to protect special-category data, including encryption in transit, access on a least-privilege basis, and processing within the secured environments described above. No method of transmission or storage is completely secure, but we take reasonable, up-to-date measures appropriate to the sensitivity of the data.

You have the right to learn whether your data are processed, to request information and access, to request rectification, erasure or destruction, to object to or request restriction of processing, to data portability where applicable, and to withdraw your explicit consent at any time without affecting the lawfulness of processing before withdrawal. To exercise any right, write to [email protected]. You may also lodge a complaint with the competent data protection authority.

Where you provide explicit consent (for example, on the case-submission form), you confirm that you have read and understood this Notice and that you give your explicit consent to the processing, for the purposes described above, of your special-category clinical and molecular (NGS) / genetic data, including AI-assisted evaluation in the EU (Frankfurt) region and the limited international transfers described in Section 7.